Citing to No-Action Letters, Staff Interpretations and Other Tricky Administrative Law Materials

Posted on Posted in Legal Writing and Citation

Rule 14 of the Bluebook is your place to look for information on how to cite the Federal Register and the Code of Federal Regulations, as well general guidance for citing proposed rules, comments, agency adjudications and arbitrations.

But once you really get into the weeds with administrative law materials, you’ll soon find that Rule 14 doesn’t cover everything you need. That’s when you might need to check table T1.2 – Federal Administrative and Executive Materials.

T1.2 is a non-exclusive list of agency and executive materials that do not conform to Rule 14 citation. Here’s where you’ll find some of the most nitty gritty agency materials and how to cite them. T1.2 is organized by agency, then by type of material. You’ll find things like –

  • SEC no-action letters, staff interpretations, releases, and filings
  • Social Security Administration (SSA) acquiescence rulings
  • Treasury private letter rulings, technical advice memoranda and bulletins
  • USPTO patents and trademarks, and
  • Government Accountability Office (GAO) bid protest decisions

Note that T1.2 may also provide additional information on how to cite the regulations and decisions of various agencies.

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